Clayton Partners LLC

Clayton Partners LLC, a SEC-registered investment adviser based in Berkeley, CA, has been in operation since 2003. The firm primarily manages assets on a discretionary basis, focusing on equity and equity-related securities in U.S. and non-U.S. markets. Clayton offers its services to high-net-worth individuals, institutions, trusts, endowments, and pension plans. The firm's fee structure for Separate Accounts ranges from 0.70% to 1.8% per year based on assets under management, with negotiable fees for family accounts. The Fund managed by Clayton typically charges a 1% annual fee and a performance allocation of 20% of net profits. Clayton's investment strategies include long-term investments in quality businesses, short positions, arbitrage transactions, and option strategies. Clayton has a Code of Ethics that outlines standards of conduct for its personnel, ensuring compliance with fiduciary obligations and securities laws. The firm may engage solicitors for client referrals and pays cash or a portion of advisory fees for such referrals. Clayton has discretion in managing client accounts, with clients able to set investment objectives and restrictions. The firm votes proxies based on the best interests of clients and maintains a privacy policy to protect client information. Additionally, Clayton complies with the DOL's Prohibited Transaction Exemption 2020-02 for retirement accounts. Clients can contact Clayton for detailed information on its brokerage practices, trade error policy, and rollover IRA policy.